Stablecoin payments infrastructure company Rain has applied to the U.S. Office of the Comptroller of the Currency to establish Rain National Trust Bank, a move that could allow the company to bring crypto custody, reserve management and stablecoin issuance under its own federally supervised subsidiary.
Rain said the proposed Rain National Trust Bank, or RNTB, would be headquartered in New York and serve institutional clients. If approved, it would provide fiduciary custody of digital assets and U.S. dollars, manage reserves for permitted stablecoin issuers and issue and redeem U.S. dollar-backed stablecoins itself.
The filing represents a potentially significant change to the infrastructure sitting behind Rain’s card, wallet and money-movement products. Those programs currently rely on a mixture of state licenses, third-party custodians and third-party stablecoin issuers. A national trust bank would allow Rain to internalize several of those functions rather than continuing to depend on multiple outside providers.
Rain Would Operate a Limited-Purpose Bank, Not a Consumer Bank
The proposed institution would be considerably narrower than a traditional commercial bank. Rain said RNTB would not accept deposits, offer consumer bank accounts or make commercial loans. It would also be uninsured by the Federal Deposit Insurance Corporation.
Instead, client assets would be held in custody for identified owners and segregated from the bank’s own assets. Rain also said reserves backing stablecoins issued by RNTB would not be pledged, lent or reused.
Rain itself would remain a payments infrastructure company rather than becoming a bank directly. RNTB would operate as a separately capitalized subsidiary supervised and examined by the OCC, while Rain’s other entities would continue supporting its existing card, wallet and payment programs.
The structure reflects a wider shift in the stablecoin market, where competition is increasingly moving beyond the token itself and into custody, payment networks, reserve management, regulatory licensing and the infrastructure connecting digital dollars to traditional finance.
Rain Wants Control Over the Full Stablecoin Payments Stack
Rain’s existing business provides stablecoin-powered payment infrastructure to enterprises, neobanks and platforms. The company says its partners operate card, wallet and money-transfer programs serving millions of end users, while Rain is a principal member of both Visa and Mastercard.
The proposed bank would take Rain deeper into the financial plumbing behind those services. Rather than connecting a customer program to an external custodian, an outside stablecoin issuer and separate reserve arrangements, Rain could potentially provide several of those functions within its own corporate group.
Brandon Soto has been named the proposed president and chief executive of RNTB, subject to regulatory review. Soto previously served as chief financial officer of Square Financial Services, Block’s Utah-chartered industrial bank, where he worked on the charter process and oversaw finance, treasury and capital management. He later served as chief financial officer of Coastal Financial Corporation and previously held senior roles at Green Dot Bank.
The application comes after a period of rapid expansion for Rain. In January, the company raised $250 million in a Series C round led by ICONIQ, valuing Rain at $1.95 billion and taking total funding above $338 million. At the time, Rain said its active card base had increased 30-fold over the previous year while annualized payment volume had grown 38-fold.
The GENIUS Act Is Reshaping Who Can Issue Digital Dollars
Rain’s application also arrives as the United States builds out its first dedicated federal framework for payment stablecoins. The GENIUS Act, enacted in July 2025, established requirements around reserves, redemption, risk management, custody, reporting and supervision. The OCC has since been developing GENIUS Act implementation rules for issuers under its jurisdiction.
That framework is already changing competitive behavior. Stablecoin companies, crypto platforms and fintech firms are pursuing bank charters or other regulated structures as they prepare for new U.S. stablecoin rules. Circle received final OCC approval for its national trust bank in July, while a broader group of digital-asset companies has pursued federal trust charters during 2025 and 2026.
Rain’s approach is particularly notable because RNTB would not simply custody stablecoins issued elsewhere. The company says the bank intends to become the issuer of record for U.S. dollar-backed stablecoins, while also administering reserves for other permitted issuers.
The application remains subject to OCC review and a public comment process. Rain said the public portion of its filing would be made available through the regulator. Approval is therefore not guaranteed, and RNTB cannot begin operations until the required regulatory authorizations are obtained.
A Charter Could Reduce Rain’s Dependence on Financial Middlemen
The most important part of this story is not that Rain wants to put the word “bank” inside its corporate structure. It is what happens to the economics and operational control of its payments business if the charter is approved.
Stablecoin payment products can look simple to the end user while depending on a surprisingly fragmented chain behind the scenes. One company may provide the card program, another holds fiat or digital assets, another issues the stablecoin, banks provide settlement accounts and still more entities handle compliance or money transmission.
Rain is effectively trying to compress part of that stack.
That resembles the broader move toward regulated banking infrastructure being built directly around blockchain-based dollars rather than simply connecting crypto products to traditional banks through layers of intermediaries.
If RNTB is approved, Rain could gain tighter control over custody, reserve operations, minting and redemption. That could reduce counterparty dependencies, make reconciliation easier and potentially allow Rain to retain more of the economics currently shared with custodians and stablecoin issuers. It could also make the platform more attractive to large enterprises that are uncomfortable relying on a long chain of third parties for regulated financial functions.
Vertical Integration Creates New Risks as Well as New Economics
There is a trade-off. Bringing infrastructure in-house does not make regulation disappear; it does almost the opposite.
A national trust bank comes with federal examinations, capital requirements, governance standards, compliance systems, reporting obligations and ongoing supervisory scrutiny. Rain would be replacing some external-provider risk with much higher internal regulatory responsibility.
There is also concentration risk. Using several independent providers creates complexity, but it can isolate failures. When custody, reserves and issuance sit within one corporate group, operational or regulatory problems at that group can affect more parts of the payment stack at once.
The political and legal backdrop is becoming more complicated too. On Oct. 2, only days before Rain announced its application, the Independent Community Bankers of America sued the OCC over its treatment of national trust charters for crypto companies. The group argues that the regulator has gone beyond its statutory authority and allowed digital-asset firms access to national charters without assuming all of the obligations imposed on conventional banks.
The lawsuit is not directed specifically at Rain and does not mean its application will fail, but it adds another variable to a chartering process that was already likely to receive close scrutiny.
The Bigger Bet Is That Stablecoin Infrastructure Becomes Banking Infrastructure
Rain’s strategy makes sense if stablecoins continue moving from crypto trading tools into mainstream payment infrastructure.
In that world, the valuable companies may not simply be the firms that issue the largest stablecoin. They may be the companies that control the regulatory licenses, custody relationships, reserves, payment rails, merchant access and software connecting stablecoins to businesses.
Rain already occupies part of that stack through cards, wallets and payment infrastructure. A national trust bank would move it further upstream, closer to the actual creation and safeguarding of the digital dollars moving through those products.
That creates an opportunity to capture more revenue from each transaction and build a stronger regulatory moat. It also raises the cost of execution. Rain would need to prove that it can operate bank-grade controls while maintaining the speed expected from a fintech infrastructure company.
For investors and competitors, that is the metric worth watching. The question is not simply whether Rain receives the charter. It is whether federal supervision allows Rain to turn stablecoin payments from a business assembled through partnerships into infrastructure it increasingly owns itself.
Johan Shamshad is a financial markets writer at Dave Finances covering cryptocurrencies, trading platforms, brokers, fintech, financial regulation, and developments across global markets. He previously worked at Gulf News, adding newsroom experience to his coverage of fast-moving financial and digital-asset markets.
His work focuses on identifying market-moving events, company developments, regulatory changes, product launches, and shifts in trading and financial infrastructure.
Johan contributes news and analysis designed to help readers understand not only what happened, but why a development matters and how it may affect the wider financial landscape.